Fairewinds Comments on the EPA’s Proposed Changes to the Protective Action Guidelines (PAG)

Dear Janet McCabe – EPA Acting Assistant Administrator for the Office of Air and Radiation and the EPA Docket:

Fairewinds Energy Education has prepared this brief report in response to the EPA’s suggested changes to its Radiation Protective Action Guidelines (PAGs). Specifically, the EPA is suddenly recommending a huge increase to “allowable” public exposure levels from radiation releases caused by a mishap or disaster at an atomic reactor, waste storage site, fuel production site, etc. What does this mean? It means that the EPA is arbitrarily choosing to increase human exposure levels to atomic radiation releases without conducting an adequate scientific review and without quantifying the significant health consequences to people.

Fairewinds Energy Education’s scientific review of the data has found no evidence or basis in science to allow such a health compromising transfer of risk to everyone living in the United States. Therefore, Fairewinds Energy Education strongly objects to the implementation of these proposed rule changes that will compromise public health and safety and benefit atomic corporations by allowing a significant reduction in each corporation’s mandated cleanup of costly radiation catastrophes.

The EPA is proposing that levels of 500 millirem per year are acceptable in radioactively contaminated water for general public consumption and an increase to 100 millirem per year of exposure levels to pregnant women and young children. These levels far exceed EPA’s acceptable risk range for cancercausing radiation exposure levels.

Let me simplify this for you and for readers of Fairewinds’ comments. If implemented, this proposed change in radiation guidelines greatly increase radiation exposure to people to a totally unacceptable radiation risk level. At the same time, the changes will reduce radiation disaster cleanup costs to corporations and transfer that horrific risk and cost of cleanup to states, cities, towns, and villages that will already be suffering astronomical losses.

Since the triple meltdown at Fukushima Daiichi and its decimation of much of the Fukushima Prefecture (state) due to extensive ongoing radiation releases, Fairewinds’ Chief Engineer Arnie Gundersen has traveled to Japan three times on public speaking and scientific fact finding research and analysis. Most recently, Mr. Gundersen spent one month in Japan in February of 2016 measuring the ongoing radioactive releases from the atomic disaster, and interviewing numerous “survivors”, who have been exposed to radioactive releases from the meltdowns and are continuing to be exposed to the ongoing buildup and movement of significant amounts of radioactivity. Mr. Gundersen has two degrees in Nuclear Engineering and more than 44-years of atomic energy operations and risk analysis experience.

A thorough review by Fairewinds of the evidence collected and the available published literature proves that the proposed changes to the PAGs are a convoluted attempt to shift excessive radiation risks to a population of innocent bystanders at the same time the EPA is transferring excessive profits to the corporate owners of atomic power reactors, waste storage facilities, atomic fuel producers, etc.